Yesterday, in Announcement 2012-42, the Internal Revenue Service (IRS) announced its intention to modify proposed regulations issued in February 2012 by the IRS and Treasury Department that implement a set of statutory rules commonly referred to as FATCA (the Foreign Account Tax Compliance Act).
The announcement provides welcome relief under FATCA, including for foreign financial institutions (FFIs) and other withholding agents. In issuing the announcement, the IRS is responding to comments on the proposed regulations, notably those identifying practical issues with implementing the FATCA rules within the prescribed timeframes and seeking to expand the categories of “grandfathered obligations.”
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